Arbitrary	detention	–	article	6	
Incommunicado detention in itself amounts to a gross violation of the right to liberty and
security of person, especially where the accused is not represented by a lawyer (African
Commission on Human and Peoples’ Rights v Libya, Merits, Application 002/2013, 3 June
2016, paras 84 & 85).
Detention after trial and conviction in a criminal trial does not violate the prohibition of
arbitrary detention unless there has been a ‘flagrant denial of justice’ (Alex Thomas v United
Republic of Tanzania, application 005/2013, judgment, 20 November 2015, para 150).

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